Mobilisation

This page provides information on why firms may choose the mobilisation route and the process for entering and exiting.

In this section

What is the mobilisation?

  • The mobilisation route is optional.
  • Mobilisation enables new banks to secure further investment, recruit staff, invest in IT systems and commit to third-party suppliers etc due to them being an authorised bank. Mobilisation is therefore for firms to complete the build out of the bank, including the processes, people and systems and is not to be seen as the stage to commence these developments.
  • During mobilisation, we limit the amount of total deposits that a new bank can accept to a total of £50,000.
  • Mobilisation could take as little as a few months but cannot continue indefinitely and should take no longer than 12 months. A Variation of Permission application for banks to exit mobilisation shall be required to be made at least three months prior to the expiration of the 12 month mobilisation period to allow sufficient time for the regulatory assessment.

Once a new bank is authorised, mobilisation is a period of up to 12 months where their deposit-taking permission is restricted (ie to a total of £50,000 of deposits) while they complete the remaining build out of their bank. This often enables new banks to secure further investment, recruit staff, invest in IT systems and commit to third-party suppliers etc, due to them being an authorised bank. Upon entering into mobilisation, the PRA and FCA will set a list of mobilisation conditions for the firm to meet in order to exit mobilisation. These will be focused on completing and evidencing the necessary work for the firm to fully meet the regulatory expectations and demonstrate that it is able to safely launch as a fully operational bank.

Mobilisation is sometimes referred to as ‘Authorisation with Restrictions’ or ‘AwR’. Mobilisation was introduced as an optional stage following A review of requirements for firms entering into or expanding in the banking sector.

New banks using the mobilisation route will appear on the Financial Services Register as authorised banks, but with a £50,000 limit on the total amount of deposits that they can accept.

Mobilisation should not be seen as the stage to commence a firms’ bank-building strategies, processes and systems, but rather a route which allows new banks extra time to finalise and deliver the development of their banks, ie IT infrastructure, governance and risk management frameworks, with the benefit of being authorised. As mobilisation is intended to complete the build out of the bank, we do not expect firms to make material changes to their strategy or individuals during mobilisation. Where we do observe material changes it could raise questions on the basis that the firm was authorised into mobilisation and could likely mean changes to the mobilisation conditions.

As firms will be authorised, they will be required to meet all PRA and FCA Threshold Conditions (including their capital and liquidity requirements to meet the PRA’s Threshold Condition of ‘Prudent Conduct of Business’) from the point of being authorised and ensure that they continue to meet these throughout their time in mobilisation. The mobilisation period is up to 12 months, and firms are expected to submit the Variation of Permissions application three months prior to exiting mobilisation to allow for the regulatory assessment period. Therefore, firms only have a limited amount of time in mobilisation to complete the necessary work to be operationally ready for full launch and to exit mobilisation. Due to this, the majority of the bank’s development will need to have been done in advance of being authorised.

New banks in mobilisation are set separate capital requirements to that which they must hold once authorised without restrictions. This tends to be lower than that set for the firm once it exits mobilisation as it takes account of the fact that they are not yet fully operational. We will communicate both of these capital requirements to the firm during the application assessment process. Firms must have sufficient capital resources to meet the mobilisation capital requirements from day one of the mobilisation period and ensure that they continue to meet this requirement throughout the period that they remain in mobilisation.

What are the benefits and is mobilisation right for all banks?

New banks that have taken the mobilisation route have told us that being authorised allows them to proceed with far greater confidence and to invest in the final stages and refinement of the build-out of their bank (including through further capital raising). However, within the 12 month mobilisation period, new banks will need to have completed all of their mobilisation activities, demonstrated that they will be fully operational upon exiting mobilisation and addressed any additional issues we have identified during mobilisation before they will be allowed to exit mobilisation and start to trade fully.

Mobilisation is generally suitable for start-up firms which may not have all of the upfront investment, or need that additional time to complete the build-out of their IT systems, infrastructure, recruit staff or engage with third-party suppliers. We expect firms to only use this time to complete the final stages of their development. New banks should demonstrate through their mobilisation plans that they will be able to complete all remaining developments during the period that they expect to be in mobilisation, taking account that the maximum period of mobilisation is 12 months.

Mobilisation may not be necessary for firms that have the resources, capital and infrastructure to allow them to set the bank up fully from day one of authorisation, for example an existing firm or a well-established international banking group seeking to establish a UK subsidiary or branch.

The mobilisation route is optional – but we expect firms to have clearly set out which route they are planning to adopt and why, during their pre-application engagement with us.

Upon review of the firm’s buildout plan, we will assess its feasibility and determine whether it will be deemed acceptable for the firm to use mobilisation. This will be subject to the deemed likelihood of being able to meet the Threshold Conditions at the point of entry into mobilisation and the deemed feasibility of being able to complete all required activities during mobilisation so as to minimise the risk of not being able to complete the plan within the 12-month mobilisation period.

What happens during mobilisation

Firms taking the mobilisation route will generally not have fully developed operational capabilities but they must meet all the Threshold Conditions and their capital and liquidity requirements at all times.

Assessment area
 Mobilisation route/Authorisation with restrictions
 Authorisation without restrictions/exiting mobilisation(a)
Business plan/viability
 Fully developed – consideration will be given to minor adjustments to the business plan. Material changes to either the business plan or strategic objectives may necessitate a reapplication.
 Fully developed.

Financial resources

 Fully developed – the new bank will need to meet their capital and liquidity requirements set for the mobilisation period. These requirements are set separately to the post-mobilisation requirements to reflect the restrictions applied in mobilisation on their business model.
 Fully developed – the new bank will need to meet their capital and liquidity requirements.
Sources of funding
 Fully developed for the mobilisation period.
 Fully developed for the next 12 months.
ICAAP and ILAAP
 Fully developed.
 Fully developed.
Corporate governance Structure Board Senior Management

Fully developed governance framework.

Key ‘guiding minds’ in place with senior roles critical to mobilisation identified and ready to be recruited.

Minimum Board Chair, CEO and one other Executive (usually CFO), however highly encouraged to have identified or recruited other key individuals before entering mobilisation. Firms should also have considered any other necessary hires to deliver the mobilisation plan within the 12 month period and to demonstrate effective governance for full launch.

Fully developed governance framework.

All key Senior Management staff in place.

Appropriate number of independent non-executive directors. Established good practice is at least two.

Chair must not perform an executive function and there is a strong expectation that they should be independent.

Customer journey including details of products, pricing, and on-boarding arrangements

Consumer Duty implementation approach

Near final customer journey

Near final Consumer Duty approach.

 Fully developed.
Recovery Plan
 Near final Recovery Plan.

Fully developed Recovery Plan.

Credible solvent exit analysis as part of business-as-usual (BAU) activities.(b)
Business Continuity Plan (BCP)
 Near final BCP.
 Fully developed BCP.
Risk management framework and control structures (including conduct risk and financial crime)
 Near final framework with the necessary controls in place.
 Fully developed.
IT infrastructure and systems
 Outline of how the firm intends to build-out, test and implement systems and IT infrastructure.
 Fully developed.
Material outsourcing arrangements
 Outline of approach to outsourcing and third-party arrangements, including identified providers.
 Fully developed.
Policies and procedures
 Not required but development should be planned. Where possible we would want to see early drafts of the conduct risk, financial crime and vulnerable customer policies.
 Fully developed.
Mobilisation plan
 Fully developed and signed off by the Board.
 n/a.
(a) This criteria does not all apply to international banks operating in the UK through a branch.
(b) This does not apply to international banks operating in the UK through a subsidiary.

 

During mobilisation, new banks will usually be focused on the following:

  • funding – fully capitalising the bank for when they exit mobilisation;
  • recruitment – finalising senior management appointments (encouraged to be done at an early stage of the mobilisation period to allow them to embed and feed into the build out of the bank) and other staff recruitment and training;
  • operationalising their plan:
    • finalising their customer journey, including details of products, pricing, and on-boarding arrangements; and
    • completing policies and procedures;
  • risk and controls – completing the build-out of control functions such as Risk, Internal Audit and Compliance;
  • building out their infrastructure:
    • building-out, testing and implementing systems and IT infrastructure; and,
    • finalising outsourcing arrangements;
  • developing their plans if things go wrong:
    • finalising their Recovery Plan;
    • finalising their Business Continuity Plan; and,
    • finalising their solvent exit analysis as part of BAU activities.

These activities will depend on the nature of the new bank and their business model. The list of mobilisation activities applicable to the new bank will be discussed with them prior to entering mobilisation and will be clearly articulated in their authorisation letter. Mobilisation activities do not have to be delivered in strict sequence and the new bank can decide when to complete them. Firms are however encouraged to start working on some of those activities prior to entering mobilisation as this may allow more time to complete them.

During mobilisation, the new bank will be an authorised firm and as such must meet the Threshold Conditions and the standards set out in both the FCA Handbook and the PRA Rulebook as well as their capital and liquidity requirements at all times.

While the level of capital requirements applied to new banks during mobilisation is often lower during this period, mobilisation can be very capital intensive and new banks should ensure they have adequate forward-looking capital planning in place so that they do not at any time breach their minimum capital requirements during mobilisation. Funds to meet the capital requirements must not to be used to meet the costs of mobilisation. New banks are also required to remain above their minimum liquidity requirements at all times.

New banks are expected to submit regular progress reports (including details of any issues or slippages against their mobilisation plans and timelines) to us and provide evidence of their progress towards becoming fully-operational, ie Board approved documents to evidence that each aspect of their mobilisation plan has been completed and that any additional issues we have raised have been adequately addressed.

New banks are at the start of their journey to becoming established banks and we expect them to continue to develop and mature as they progress through mobilisation. This includes:

  • ongoing development of their governance arrangements and senior management;
  • continuing to refine and embed their risk and control frameworks; and,
  • continuing to develop their forward-looking financial forecasting and risk management taking account of developments in the macroeconomic environment.

We expect firms to make us aware of any changes to their businesses models and any emerging or crystallised risks.

As soon as they are authorised, new banks are required to submit regulatory returns. The reports that will need to be submitted will be based on the regulated activities they undertake and the nature of their firm (ie if they are a UK headquartered bank, a subsidiary or a branch of an international bank). This will include providing the PRA with the information it needs to monitor their financial position and performance and the FCA with more conduct-focused information on sales, complaints etc.

New banks continue to be overseen by their PRA Supervisor and FCA Case Officer while in mobilisation. Regular update meetings will be arranged to discuss progress against their mobilisation plans and exit requirements. We will require monthly copies of regular Board papers to facilitate these discussions. We expect new banks to maintain a positive regulatory relationships with us through open and constructive communication.

We will provide new banks with regular feedback through face-to-face meetings, telephone calls or by email. As firms progress through mobilisation, we expect that our relationship will evolve as new banks become more accustomed to the regulatory relationship. Firms need to demonstrate that they are moving towards becoming more aware of our expectations and are becoming more independent in delivering against these.

How do banks exit mobilisation?

We anticipate that new banks will want to progress quickly through the mobilisation phase. This could take as little as a few months but cannot continue indefinitely and should take no longer than 12 months. In order for a new bank to exit mobilisation, they should submit a Variation of Permission (VoP) application via Connect. Banks are to ensure that the VoP application has undergone a thorough governance approval process and received sign-off prior to its submission. As part of the VoP application (or ideally beforehand), new banks need to submit evidence that all actions and mobilisation conditions set out in their Authorisation letter relating to their mobilisation requirements and any other actions we have requested from the firm while they have been in mobilisation have been completed. As we continuously engage with banks during mobilisation, we highly encourage firms to submit the aforementioned evidence as soon as its available (ie before submitting a VoP application, if feasible). Our assessment of new banks is ongoing throughout the mobilisation period – our interactions will help to determine whether the new bank is likely to continue to meet PRA and FCA Threshold Conditions and their regulatory capital and liquidity requirements once they exit mobilisation.

It usually takes a minimum of three months for us to assess VoP applications for new banks exiting mobilisation. However, new banks need to discuss timeframes with us and build this into their planning. Similar to a New Authorisation application, we have a statutory obligation to assess VoPs within six months of an application being deemed complete and within 12 months for an incomplete application. More information on the VoP process can be found at Variation of permission.

New banks will need to consider the number and complexity of their mobilisation actions when putting together their mobilisation plans and timelines. They should also be mindful of the timings of their plans and allow for sufficient time for us to complete the assessment of their VoP application. We will discuss these timelines with firms during the application process.

Once the VoP is approved, the new bank will be sent written confirmation that the limitation on the total deposits they can accept has been removed and they can start to trade fully. Changes to a firm’s permissions (for example removal of restriction on deposit taking) will be reflected for the new bank on the Financial Services Register from the date on which the VoP takes effect.

What if there are problems during mobilisation?

In our experience, new banks often underestimate the amount of time they will spend in mobilisation. In particular, the amount of time it takes to build, test and implement IT systems can be a lot greater than expected. It is therefore important that mobilisation should not be seen as a route to commence a firms’ bank-building strategies, processes and systems, but rather a route to allow new banks that extra time to finalise and refine the development of their bank. A firm’s ability to deliver against its pre-agreed mobilisation plan within the mobilisation period gives key insight into a firm’s readiness to exit mobilisation as well as the firm’s operational and governance effectiveness.

We encourage new banks to ensure that their timetables include appropriate levels of contingency while bearing in mind our expectation that mobilisation should not take longer than 12 months.

We do not normally allow new banks to remain in mobilisation beyond a 12-month period but we understand that there may be some circumstances that are beyond a new bank’s control that may have a bearing on their ability to exit mobilisation within the 12-month period. New banks should discuss with us at the earliest opportunity if they believe they may not meet this timeline. Similarly, if we have concerns about the new bank’s progress, we will discuss these with them and may ask them to prepare a revised mobilisation plan.

There may also be additional concerns that emerge during mobilisation and have not been included in the new bank’s mobilisation plans – for example, concerns around effective governance or culture. In this case, the firm will need to demonstrate that they have adequately addressed the issue (such that they meet Threshold Conditions) and that they have put in place controls to prevent such an issue reoccurring in the future. This will need to be evidenced before the mobilisation restrictions are lifted.

If the new bank is unable to complete mobilisation within 12 months, or to the required standard, we may take steps to remove the new bank’s authorisation or they may decide to apply to cancel their authorisation.

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This page was last updated 13 March 2026